Bonilla v. Yabuno
- Phyllis Hamilton
- 4:24-cv-08555
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Yabuno, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla showed no imminent danger and the lawsuits were legally barred.
Steven Wayne Bonilla’s multiple civil-rights lawsuits were dismissed with prejudice. The pending motions in those cases were terminated, the cases were closed, and later documents submitted in them were to be returned without filing.
What happened
In Bonilla v. Yabuno, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against federal and state judges and other officials. The lawsuits challenged his conviction or the way other state and federal cases were handled.
The court said Bonilla could not proceed without paying the filing fee because he had previously been disqualified from proceeding without fees and had not shown that he faced imminent danger of serious physical injury when he filed. The court also said that, even if he could proceed without fees, the lawsuits were barred by several legal rules and cases. It dismissed the cases with prejudice.
Judge Hamilton also rejected the suggestion that her impartiality could reasonably be questioned because of the repetitive and frivolous filings. The clerk was ordered to terminate all pending motions, close the cases, and return without filing any further documents Bonilla submitted in those closed cases.
The detailed version
- Bonilla v. Yabuno · No. 4:24-cv-08555
- Phyllis Hamilton
- Dec. 16, 2024
Background
Steven Wayne Bonilla, a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute for claims against state officials. He is also a condemned prisoner with a pending federal petition challenging his detention or conviction, in which he has appointed counsel, and he is represented by counsel in state proceedings. The complaints in these cases were nearly identical. They named various federal and state judges and other officials and sought relief concerning Bonilla’s underlying conviction or the handling of his other cases by state and federal courts.
Filing-fee restriction
The court stated that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee unless he was in imminent danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such imminent danger. It therefore held that Bonilla could not proceed without paying the filing fee.
Other legal bars and disposition
The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under the rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion does not provide a separate claim-by-claim explanation of which bar applies to which lawsuit. The court dismissed the cases with prejudice.
Impartiality and case administration
The court rejected the position that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. It noted that the judge had a duty to decide assigned cases absent legitimate grounds for recusal. The clerk was ordered to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any further documents Bonilla submitted in those closed cases.
Result
The order disposed of the cases on filing-fee and other threshold legal grounds rather than deciding the underlying civil-rights claims. It also terminated pending motions and closed the listed cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.